PROMETEIA. Innovation Fund

Privacy Policy and Cookie Policy

Last updated:

This is an English translation provided for convenience. In case of any discrepancy, the Polish version prevails.

Rules for the processing of personal data by Prometeia Innovation Fund ASI sp. z o.o. and for the use of cookies on the vc.prometeia.pl website.

Privacy Policy

§1. Introduction – basic information

This Privacy Policy (the “Policy”) sets out how Prometeia Innovation Fund ASI sp. z o.o., with its registered office in Wrocław (the “Fund”), uses (processes) the personal data of visitors to the website (domain: vc.prometeia.pl) administered by the Fund, and of persons with whom the Fund establishes, or who establish with the Fund, contact by e-mail (together, the “Users”).

We respect the privacy of our Users and therefore make this Policy available so that every User knows to what extent their personal data are processed and can decide independently, knowingly and freely whether to use our website and e-mail correspondence.

In this Policy we describe, in general terms, how, on what basis and to what extent we collect Users’ personal data, for what purposes we use them, to whom we disclose them and how we protect them. The Policy also explains the rights Users have under applicable data protection law.

The Policy is general in nature and presents the most important issues related to the processing of personal data. Additional or supplementary information on the processing of personal data by the Fund, in particular investors’ data, is provided in contractual documentation or in information notices given to those persons.

To the extent that we use cookies on our website, further information is provided in the Cookie Policy.

CONTROLLER — CONTACT DETAILS

Prometeia Innovation Fund ASI sp. z o.o., with its registered office in Wrocław at ul. Strzegomska 138, 54-429 Wrocław, Poland, entered in the Register of Entrepreneurs of the National Court Register (KRS) maintained by the District Court for Wrocław-Fabryczna in Wrocław, VI Commercial Division of the National Court Register, under number 0000619039; NIP (Tax ID): 8943078770; REGON: 364477059. Website: vc.prometeia.pl, e-mail: biuro@prometeia.pl.

§2. Data protection legislation

The Fund’s Privacy Policy is based on the following legislation:

  • Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (“GDPR”),
  • the Polish Personal Data Protection Act of 10 May 2018,
  • the Polish Electronic Communications Law of 12 July 2024,
  • the Polish Act of 18 July 2002 on the Provision of Electronic Services.

§3. Principles of processing your personal data

When processing Users’ personal data, we take care that the data are processed securely, reliably, lawfully and transparently for the User. The most important principles we follow are:

  • we collect personal data only to the minimum extent necessary for the purposes for which they are collected;
  • the purposes of collecting Users’ personal data are clearly defined and based on the law – we do not process data in a manner incompatible with those purposes;
  • we keep Users’ personal data up to date and accurate, and respond promptly to requests for their rectification or update;
  • we give effect to Users’ rights of access to their data, rectification, erasure, withdrawal of consent, restriction of processing, data portability, objection and the right not to be subject to a decision based solely on automated processing, including profiling;
  • we limit the storage of personal data to the period necessary for the purposes for which they are collected, unless the law requires longer storage;
  • we protect Users’ personal data against loss, unauthorised access, accidental alteration and other unlawful forms of processing;
  • where personal data are disclosed to other entities, this is done securely, under contractual safeguards and in compliance with applicable law.

§4. Users’ rights relating to the processing of personal data

The Fund gives effect to Users’ rights relating to the processing of their personal data, arising in particular from Articles 15–21 GDPR. The User has the right to:

  • withdraw consent to the processing of personal data at any time, where consent is the legal basis for the processing;
  • information on how the Fund processes their personal data;
  • access to data: to obtain confirmation from the Fund as to whether and how personal data are processed, and access to them, to the extent provided for in Article 15 GDPR;
  • rectification of outdated or inaccurate personal data, and completion of incomplete data;
  • object to the processing of personal data on grounds relating to their particular situation where we process data on the basis of our legitimate interest – in that case we will stop the processing unless we demonstrate compelling legitimate grounds that override your interests, or grounds for the establishment, exercise or defence of legal claims;
  • not be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning the User or similarly significantly affects them;
  • erasure of personal data (“right to be forgotten”), subject to the exceptions provided for in Article 17 GDPR;
  • restriction of the processing of personal data;
  • data portability – to receive a copy of the data you have provided to us, where the processing is based on consent or a contract and is carried out by automated means;
  • lodge a complaint with the supervisory authority – the President of the Personal Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych, ul. Stawki 2, 00-193 Warsaw, Poland).

Any requests concerning processed personal data may be sent by e-mail to biuro@prometeia.pl or in writing to: Prometeia Innovation Fund ASI sp. z o.o., ul. Strzegomska 138, 54-429 Wrocław, Poland.

Requests will be handled without undue delay and in any event within one month of receipt. This period may be extended by a further two months owing to the complexity or number of requests, in which case we will inform you. To handle certain requests we may need to verify the User’s identity.

§5. Security of personal data

The Fund applies technical and organisational measures to protect the User’s personal data against unlawful and unauthorised access or use, as well as against accidental destruction, loss or loss of integrity. The website is provided over an encrypted connection (HTTPS).

In ensuring the security of the personal data processed, we undertake to take into account:

  • confidentiality – we protect data against accidental disclosure to third parties,
  • integrity – we protect data against unauthorised modification,
  • availability – we ensure that authorised persons have access to the data where necessary.

Personal data may be processed by third parties only where such an entity undertakes to ensure appropriate technical and organisational security measures and to keep the data confidential. Every person with access to personal data on behalf of the Fund holds the relevant authorisation and is bound by confidentiality.

§6. Processing of personal data

The Fund processes personal data only for specified, explicit and legitimate purposes.

Consent (Article 6(1)(a) GDPR) – is the legal basis for the use of cookies other than strictly necessary ones, including statistics cookies (more in the Cookie Policy).

Performance of a contract or steps taken prior to entering into a contract (Article 6(1)(b) GDPR) – applies where correspondence concerns the conclusion or performance of a contract with the Fund.

Legitimate interests (Article 6(1)(f) GDPR) – we may process personal data on the basis of our legitimate interests, consisting in:

  • handling e-mail correspondence and enquiries addressed to the Fund;
  • maintaining ongoing relationships with partners, portfolio companies, investors and counterparties;
  • ensuring the operation and security of the website (including server log analysis);
  • evidential and archival purposes and the establishment, exercise or defence of legal claims;
  • giving effect to Users’ rights and keeping records of how they were handled.

Legal obligation (Article 6(1)(c) GDPR) – concerns obligations imposed on the Fund by law, in particular tax and accounting law and the law on alternative investment companies.

The Fund collects Users’ personal data when they contact us by e-mail or telephone. The website contains no contact forms. The login fields in the investor area do not transmit or store the data entered. When the website is used, data contained in server system logs and – with the User’s consent – in cookies are collected automatically (more in the Cookie Policy).

We may process personal data such as: identification data (e.g. first name, surname), contact data (e.g. telephone number, e-mail address), information contained in correspondence addressed to or from the Fund and, for businesses, also the company name, tax identification number (NIP) and the position of the contact person. For businesses, data may come from publicly available registers (including KRS and CEIDG).

Providing personal data is voluntary but necessary in order to respond to correspondence.

The Fund does not knowingly process personal data of persons under 16 years of age.

§7. Consent and its withdrawal

Consent to the use of cookies other than strictly necessary ones is given in the banner displayed on the first visit to the website. You may change or withdraw it at any time by clicking the cookie settings icon in the corner of the screen or the Change cookie settings link.

Withdrawal of consent has no negative consequences and does not affect the lawfulness of processing carried out on the basis of consent before its withdrawal.

§8. Data retention

Data will be stored for as long as necessary to achieve the purposes for which they were collected. The basic retention periods adopted are:

  • e-mail correspondence – for the period necessary to handle the matter and then until the limitation periods for any claims expire;
  • data processed as part of business relationships – for the duration of the cooperation and then until the limitation periods for claims expire;
  • Google Analytics statistical data – 2 months;
  • data processed to fulfil legal obligations – for the period required by law.

§9. Recipients of data

The Fund is not a joint controller of personal data. Data may be entrusted to entities processing them on the Fund’s behalf under data processing agreements, in particular:

  • the hosting provider (nazwa.pl sp. z o.o.),
  • the provider of e-mail and office tools (Microsoft),
  • the provider of the analytics tool (Google Ireland Limited / Google LLC) – only after consent to statistics cookies has been given,
  • the provider of the consent management platform (Usercentrics A/S – Cookiebot),
  • entities providing accounting, legal, advisory and IT services to the Fund.

Data may also be disclosed to entities authorised under the law.

§10. Processing of data outside the EEA

If, as part of the processing, Users’ personal data are transferred to recipients in third countries (outside the EEA), e.g. in the United States, such transfers may take place on the basis of an adequacy decision of the European Commission — in particular the decision of 10 July 2023 concerning the EU-US Data Privacy Framework — or on the basis of standard contractual clauses approved by the European Commission.

§11. Processing of data using cookies

In connection with the User’s use of the website, the Fund also collects data contained in system logs and – with the User’s consent – in cookies. Further information can be found in the Cookie Policy below.

§12. Changes to the Policy

The Fund reserves the right to amend this Policy, which may result from the need to adapt it to changes in the law, applicable privacy standards or the functionality of the website. The Fund will announce any changes by means of a notice on the website.

§13. Information on the website

The information published on the website is for information purposes only and does not constitute an offer within the meaning of the Polish Civil Code, a public offering, an investment recommendation or an inducement to acquire shares or other financial instruments.

LAST UPDATED: 5 OCTOBER 2026

§1

This Cookie Policy concerns the use of cookies and the processing of personal data by means of them on the vc.prometeia.pl website, administered by Prometeia Innovation Fund ASI sp. z o.o. with its registered office in Wrocław at ul. Strzegomska 138, 54-429 Wrocław, Poland, KRS: 0000619039, NIP: 8943078770, REGON: 364477059. The Cookie Policy supplements the Privacy Policy.

§2

Cookies are IT data, in particular text files, stored on your terminal device (e.g. computer, tablet, smartphone) and intended for use with websites. Cookies are harmless to you and your devices, do not affect their operation and do not change their configuration.

The website uses session and persistent cookies in the following categories:

  • strictly necessary – enabling the use of the website and remembering your cookie consent choices; you cannot disable them because they are required for the website to work properly;
  • statistics – collecting information about how you use the website (e.g. pages visited, visit duration, traffic source); these data are used to produce aggregate statistics.

We do not use advertising or marketing cookies on the website, we do not carry out remarketing and we do not profile Users.

When statistics cookies are used, the following may be processed, among others: device and browser data (e.g. device type, operating system version, language settings), IP address, approximate location (at country or city level) and information on how the website is used.

§3

We use cookies other than strictly necessary ones only after obtaining your explicit consent, given in the banner displayed on the first visit to the website. Until consent is given, scripts requiring consent are blocked. Merely browsing the website is not treated as consent.

You may change or withdraw your consent at any time by clicking the cookie settings icon in the corner of the screen or the Change cookie settings link. Withdrawal of consent does not affect the lawfulness of processing carried out before its withdrawal.

You may also change your browser settings so that it asks for cookies to be accepted, accepts or rejects only certain types, or rejects all cookies. Cookies can be deleted using browser functions or operating system tools.

§4

We use the cookies applied for the following purposes:

  • ensuring the proper operation and security of the website;
  • remembering your cookie consent choices;
  • analysis and statistics that help us understand how you use the website, enabling us to improve its structure and content.

§5

We use the services of the following providers on the website:

  • Google Analytics – a tool collecting information about visits to the website in order to generate aggregate statistics; we use Google Consent Mode – without your consent, Google Analytics does not store cookies on your device;
  • Cookiebot – a cookie consent management tool that records your choice and keeps a register of consents given.

The website contains links to other websites (e.g. prometeia.pl) – if you use them, you leave our website, and the privacy and cookie policies of their administrators apply.

Detailed information on external providers:

  • Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (affiliate: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA) — policies.google.com/privacy
  • Usercentrics A/S (Cookiebot), Havnegade 39, 1058 Copenhagen, Denmark — cookiebot.com/privacy-policy

In connection with the use of Google Analytics, some data may be transferred outside the European Economic Area. Transfers of data to the United States take place on the basis of the European Commission implementing decision of 10 July 2023 establishing an adequate level of data protection under the EU-US Data Privacy Framework, in which Google LLC participates.

List of cookies used

The list below is generated and updated automatically and contains the current list of cookies used on the vc.prometeia.pl website, together with their provider, purpose and retention period.

§6

Any additional questions and information relating to this Cookie Policy may be sent to biuro@prometeia.pl or by post to the address given in §1. The Fund reserves the right to amend this Policy.

LAST UPDATED: 5 OCTOBER 2026